Question 1: Since the internal audit is required in middle of our designation period and my agency’s designation is past our halfway point, what is our internal audit timing?
Answer: If your OA’s designation and/or interim designation ends during CY24, then an internal audit is not required at this time (Cal-Agri, Idaho Grain, Ohio Valley, Virginia, and Michigan Grain). If your agency is currently being audited by QACD (Washington, Lincoln, Mid-Iowa, Minot, Kansas Grain, and Tri-State) the IAP directive will apply for when the OA is re-designated.
However, if your current designation ends after CY24, you must submit an internal audit to QACD per the IAP Directive. For example, if your 5-year designation ends 12/31/2025 and your halfway point was 6/30/2022, then you are still required to submit an internal audit by 12/31/2024.
Extensions can be requested based on case-by-case situations to QACD. If applicable, submit your question and/or request directly to Tanner.Fye@usda.gov and ShawnWah.O.Lee@usda.gov. Please include your Liaison Officer in the email for their awareness.
Question 2: Does QACD plan to hold an in-residence training course that pertains to the new IAP?
Answer: Yes, QACD plans to host a in-residence training course led by some of our staff members. However, at this time we are uncertain of the dates. This will depend on FY budget and audit scheduling. QACD plans to send out an email in advance letting all OSPs know the date and timeframe this course will be available.
Question 3: What does the statement, “OAs must conduct an internal audit by the halfway date of their designation period” mean?
Answer: This means that the OA must submit IAP including any root cause analysis and corrective action plan by halfway date of the designation period.
Note: Once QACD receives an electronic submission with the required documents, please allow a minimum 60 days for evaluation. If additional information is required, QACD will notify the OA in writing within the 60-day evaluation period. If the OA does not provide the requested information within 10 business days, QACD will dismiss the proposed IAP. Extension requests, accompanied by a justification, must be submitted to QACD a minimum of 60 days prior to the halfway date of your designation period.
Question 4: Do I have to fill out section 4 (preventive action) on the Corrective Action Plan Document for a noncompliance?
Answer: No. This section is labeled “when applicable”. A preventive action is defined as actions taken to address and eliminate the cause of a potential non-compliance. Preventive action is essentially risk mitigation. It involves taking proactive steps to ensure a potential non-compliance does not occur. Preventive actions may be reactionary to implementing a corrective action (if additional issues are identified during the process) or because of QACD audits, internal audits, employee reporting, or customer feedback.
Example #1: Performing regular maintenance on equipment and machines to ensure they are working properly and to reduce the chance of breakdowns.
Example #2: Establishing a written procedure outlining the proper way to handle hazardous materials and providing training to employees.